Privacy Policy

Privacy Policy

With the present privacy policy, SocialstartS.r.l. informs its users that the Personal Data provided while registering and using the Portal www.whatspass.com (hereafter “Portal”) and any further information collected by SocialstartS.r.l. by any means in compliance with the aims described below may be processed following the legislative decree 196 of June 30th, 2003 (following the amendments to the Italian “Privacy Code”, Codice della Privacy). According to the aforementioned legislation, the data processing will be based on the principles of correctness, legality, transparence and protection of privacy and of the rights of the Users of the Portal. Providing data or consenting to their processing is not mandatory, but refusing one or the other will prevent the User from using the services provided by the Portal.

Data processing owner

The data processing owner is Socialstart S.r.l., whose legal seat is located in Rome, Via Terenzio 10. National identification number/VAT number 12633091009 (hereafter “Socialstart”) represented by the natural person Emilio Meschini, who is also the Supervisor of data processing.
Some of the data may be processed during some activities (or part of such activities) to pursue the data processing objectives. In those cases the same subjects will operate as independent owners or will be designated as data processing Supervisors. The people that may be designated as Supervisors will be given adequate operational instructions with specific reference to the minimal safety measures to comply to in order to guarantee the safety and privacy of the data. The aforementioned third parties are mostly consulting agencies, meaning subjects of another nature with specific authorization or responsibilities to take part in the services provided by the Portal, in other words to manage/create phases or activities of the same project.

Types of collected data

The personal data collected autonomously by the Portal or via third parties include: cookies, navigation and usage data, first and last name, gender, date of birth, phone number, address, username, e-mail address, password, business name, national identification number, VAT number, occupation, fax number, county, state, country and geographic position.
Other collected personal data may be indicated in other sections of this privacy policy or through informational texts shown in the context of the data collection.
Personal Data may be entered voluntarily by the User or collected automatically while using the Portal and its services.
The possible use of cookies – or other tracking tools – by the Portal or the owners of third party services used by the Portal is, unless otherwise specified, to identify the User and register their preferences to provide at best the services requested by the User. Navigation on the Portal implies automatic consent to the Cookie Policy of the Portal.
If the User chooses not to communicate certain types of personal information, the Portal may experience difficulties in providing its services.
The User is responsible for the Personal Information of third parties published or shared through the Portal and ensures having the right to communicate or disclose them, and releases Socialstart from any responsibility towards third parties and from the obligation to carry out prior verifications or assessments.

Data processing method, location and duration

Processing Methods

The owner processes the Users’ personal data while complying to the appropriate security measures to prevent un-authorized access, disclosure, changes or destruction of personal information. Data is processed with computerized or telematic tools, in a mindset and framework that are closely tied to the indicated goals. In some cases, categories of delegates other than the owner working on the organization of the website (administration, commercial, marketing, legal personnel, system administrators), meaning outside persons (such as third-party technical service providers, IT companies, communication agencies) who can also be named Data Processing Supervisors by the Owner may have access to personal data. The up-to-date list of persons named Supervisors may always be requested to the Owner.

Venue

Data is processed in the operative seats of the Owner and any other place where the involved parties are located. For more information, you may contact the Owner using the Socialstart certified e-mail.

Duration

Data is processed for the time necessary to provide the services requested by the User or requested by the ends described in this document, and the User may ask to stop the process or delete their information at any given time.

Data processing objectives

User information is collected and used by Socialstart to allow the Portal to provide its services, as best described in the Terms and Conditions, and for the objectives listed below: social applications, statistics and market surveys, interaction with social networks and external platforms, registration and authentication, payment management, contacting the user and managing possible complaints or litigations, comment on the contents, geo-localization, advertising, showing contents from outsider platforms.
The type of information collected for each purpose is indicated in the specific sections of this document.

Details on personal data processing

Personal data is collected for the following reasons and using the following services:

Social apps

These services allow the Portal to collect information from the User’s profile on social networks and to interact in their name. These services may be activated automatically but they require explicit consent from the User.

Access to Facebook Account (This Portal)

This service allows the Portal to log in to the social network Facebook – provided by FacebookInc – with the User’s account.
Required permissions: Access to private information, status updates, current city, sharing, e-mail, pictures, send notifications, post app activity, post to wall and About Me section. For more information on the permissions that follow, the User may refer to Facebook permissions and Facebook’s privacy policy.
Processing venue: USA

Access to Twitter Account (This Portal)

This service allows the Portal to log in to the social network Twitter – provided by TwitterInc – with the User’s account.
Collected personal data: various types of information. For more information on the permissions that follow, the User may refer to Twitter permissions and Twitter’s privacy policy.
Processing venue: USA

Access to LinkedIn Account (This Portal)

This service allows the Portal to log in to the social network LinkedIn – provided by LinkedInInc – with the User’s account.
Collected personal data: various types of information. For more information on the permissions that follow, the User may refer to LinkedIn permissions and LinkedIn’s privacy policy.
Processing venue: Ireland

Comment on the contents

The comment services allow the User to express and disclose their own comments on the contents of the Portal.
Users may leave their own comment in a conditional form. In case the personal data disclosed by the User contains the e-mail address, it may be used to send notifications of comments regarding the same contents. The User is responsible for the contents of their own comments.
In case there is a comment section provided by a third party, said Third Party may collect navigational data on the pages with said service that the User visits even if the User does not use the comment service.
Collected personal data: Cookie, navigational data, e-mail, name and username.

Contact the User

Mailing List or Newsletter (This Portal)

Upon registration to the Portal, the User’s e-mail address is automatically added to a list of contacts to whom e-mails containing Portal-related information, including promotional and commercial information, may be sent.
Collected personal data: Last name, cookies, navigational and usage data, e-mail, country, first name, county and state.

Geo-localization

Geo-localization (This Portal)

The Portal may collect, use and share at any given time information on the geographic position of the User in order to provide services based on position.
The majority of browsers and devices have default tools to deny geographic tracking.
If the User gives express consent, the Portal will receive information on its effective geographic position.
Collected personal data: geographic position.

Payment management

The payment management services may allow the Portal to process payments via credit card, bank transfer or other tools. To ensure top security, the Portal entrusts the entire operation to financial intermediaries, communicated to the User each time. The intermediaries manage the payment systems with only the information necessary for the transaction.

Interaction with social networks and outside platforms

These services allow the Portal to interact with social networks or other outside platforms directly from the pages of the Portal. The interactions and information collected by the Portal are always subject to the privacy settings of the User on each social network.
If there is an interaction service installed for social network, it may collect navigational data on the pages where it is installed even from Users that do not use the service.

Tweet button and Twitter social widgets (Twitter)

The Tweet button and the Twitter social widgets are services that interact with the social network Twitter – provided by TwitterInc.
Collected personal data: cookies and navigational and usage data.
Processing venue: USA – check the relative privacy policy

+1 button and Google+ social widgets (Google)

The +1 button and the Google+ social widgets are services that interact with the social network Google+ – provided by GoogleInc.
Collected personal data: cookies and navigational and usage data.
Processing venue: USA – check the relative privacy policy

LinkedIn button and social widgets (LinkedIn)

The LinkedIn button and the social widgets are services that interact with the social network LinkedIn – provided by LinkedInInc.
Collected personal data: cookies and navigational and usage data.
Processing venue: USA – check the relative privacy policy

Like button and Facebook social widgets (Facebook)

The Like button and the Facebook social widgets are services that interact with the social network Facebook – provided by FacebookInc.
Collected personal data: cookies and navigational and usage data.
Processing venue: USA – check the relative privacy policy

Advertisement

These services allow using User Data for various forms of commercial communication including banners, and connected to the User’s interests.
This does not mean that all personal data is used for this means. Data and conditions are indicated below.
Some of the services indicated below may use cookies to identify the User or use behavioral retargeting techniques to show personalized advertisement based on the interests and the behavior of the User, as gathered on the Portal and outside. For more information on the matter, please check the privacy policies of the services.

Direct Email Marketing (DEM) (This Portal)

This Portal uses User Data to send commercial messages linked to services and products provided by third parties or not related to the products and services provided by the Portal.
Collected personal data: e-mail, name, last name, username.

Registration and authentication

Upon registration, the User authorizes the Portal to identify them at any time and to give them access to dedicated services.
Conforming to the contents below, the registration and authentication services may be provided by third parties.
If that were to be the case, the Portal may have access to information kept by the third party for registration or authentication.

Facebook Authentication (Facebook)

Facebook Authentication is a registration and authentication service provided by FacebookInc. connected to the social network Facebook.
Collected personal data: various types of information.
Processing venue: USA – check the relative privacy policy.

Linkedin Oauth (Linkedin)

Linkedin Oauth is a registration and authentication service provided by LinkedinInc. connected to the social network Linkedin.
Collected personal data: various types of information.
Processing venue: Ireland – check the relative privacy policy.

Direct Registration (This Portal)

The User registers by filling up the registration form and providing their data directly to the Portal.
Collected personal data: National Identification Number, Last Name, Date of Birth, E-mail, Address, First Name, Fax Number, Telephone Number, VAT Number, Password, Occupation, Business Name, Gender and Username.

Statistics

The services in this section allow the Owner to monitor and analyze navigational data and keep a track of the behavior of the User.

Google Analytics (Google)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google uses the collected Personal Data to trace and analyze Portal uses, produce reports and share them with other services developed by Google.
Google could use Personal Data to contextualize and personalize its own advertising network.
Collected personal data: Cookies, navigational data, usage data.
Processing venue: USA – check the relative Privacy Policy.

Viewing contents from third party platforms

These services allow the Portal to display contents hosted on third party platforms on its pages and allow the User to interact with such contents directly.
If such a service is installed, it may collect navigational data on the pages where it is installed even if the User does not use the service.

Video Youtube (Google)

Youtube service providing video contents that belongs to Google Inc. It allows the Portal to integrate video contents to its pages.
Collected personal data: Cookies, navigational data and usage data.
Processing venue: USA – check the relative Privacy Policy.

Further Information on Data Processing

Defense in court

The User’s personal data may be used by the Owner in court or during the preparatory phases, in case of abusive use of the platform or of the connected services by the User.
The User is informed that public authorities may demand that the Owner reveal personal data.

Specific information

Upon the User’s request, the Portal may provide them with contextual information on specific services or the collection and processing of personal data, completing the information held in this privacy policy.

System logs and Maintenance

For operating or maintenance reasons, the Portal and third party services it may use may collect system logs: files that record interactions and that may contain some personal data such as the User’s IP address.

Information not contained in this privacy policy

More information on Personal Data Processing may be requested to the Owner at any time using the contact information.

Exercising User’s rights

Subjects to whom personal data refer to have the right to obtain at any time the confirmation of existence or absence of personal data from the Owner, to know their contents and origins, to verify their exactitude and request integration, deletion, update, correction, transformation into anonymous form or to block personal data processed illegally, or to oppose their being processed – for legitimate reasons. Such requests must be addressed to the Processing Owner.
The Portal does not support the “Do Not Track” requests. To find out if possible third parties support them, check their privacy policies.

Changes to the present privacy policy

The Owner reserves the right to change the present privacy policy at any time, by advertising it to the Users on this page. Please visit this page regularly and take note the date of the last update below. Users who do not accept the changes made to the present privacy policy must stop using the Portal and may request that the Owner deletes their personal data. Unless otherwise specified, the previous privacy policy will be applied to the personal data collected until then.

Definitions and legal references

DEFINITIONS

Personal Data (or Information)

Any information on an identified or identifiable natural person – even indirectly through other information, including personal identification numbers – is considered Personal Data.

Usage data

The personal data collected automatically by the Portal (or the third party applications that use the Portal), including: IP addresses or domain names of the computers used by Users connecting to the Portal, URI (Uniform Resource Identifier) addresses, the time at which requests are made, how requests are made to the server, the size of the answer file, the numeral code indicating the status of the server answer (successful, error, etc.) the country of origin, browser characteristics, characteristics of the OS of the User, various time connotations on the visit (such as the amount of time spent on each page) and details on the navigation within the Portal, especially the sequence in which pages were visited, OS settings and the User’s IT environment.

User

The individual who uses the Portal, who may be the person concerned or authorized by the person concerned, and whose personal data is processed.

Person concerned

The natural person or legal entity to whom the personal data refers.

Data Processing Supervisor (or Supervisor)

The natural person, legal entity, public administration, or any other body, association or institution appointed by the Owner to personal data processing, following the rules set by the present privacy policy.

Data Processing Owner (or Owner)

The natural person, legal entity, public administration or any other body, association or institution under whose jurisdiction the decisions on the purpose, means, and tools of personal data processing are. This includes the security profile connected to the Portal use. Unless otherwise specified, the Owner is the proprietor of the Portal.

Portal

The hardware or software tool with which the Personal Data of the Users is collected.

Promoter

The natural person, legal entity, public administration or any other body, association or institution involved in the activities provided by the Portal by presenting their project to the Users.

Legal references

Notice for Users: The present privacy policy has been written following the obligations provided for in the article 13 and the following amendments/integrations of the legislative decree 196 of June 30th, 2003 (Italian Privacy Code: Codice della Privacy), of the directive 95/46/EC, and the directive 2002/58/EC as updated by the directive 2009/136/EC on cookies.
This privacy policy is applicable only to this Portal.

Right to access personal data

Owner indicated above. In the same way, the person concerned has the right to obtain a confirmation of the existence or absence of their personal data, even before their registration, and to have them communicated in an intelligible form.
The person concerned also has the right to obtain the following information:

  1. the origin of the personal data;
  2. the means and ends of the processing
  3. the logics applied in case the data is processed with electronic tools;
  4. the identification details of the owner, of the supervisors and of the representative appointed according to article 5 paragraph 2;
  5. the subjects or categories of subjects to whom the personal data may be communicated or who may become acquainted with them as representatives appointed by the State territory, supervisors or delegates.

The person concerned also has the right to:

  1. update, correct, or integrate the personal data;
  2. delete, transform to anonymous form or block personal data processed illegally, including data that does not need to be kept for the ends for which data was collected or later processed;
  3. obtain proof that the operations described above at a) and b) were brought to the attention of all who were acquainted with the personal data, except in the cases in which it would be impossible or require clearly disproportionate efforts for the right that is being protected.

The person concerned has the right to oppose to the entirely or to a part of:

  1. processing data relevant to the ends for which it was collected – for legitimate reasons
  2. al trattamento di dati personali che lo riguardano a fini di invio di materiale pubblicitario o di vendita diretta o per il compimento di ricerche di mercato o di comunicazione commerciale.

To exercise the rights provided for by the article 7 of the Italian Privacy Code, the person concerned may address Socialstart S.r.l. following the procedure provided for in the article 9 of the same code, and preferably via registered mail sent to: SOCIALSTART SRL
Att.ne Responsabile Trattamento Dati
Via Terenzio, 10
00193 - Roma
e-mail: info@whatspass.com

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